## Facts

- Melissa Globetti, age 33, gave birth in 1993 and was generally healthy, with no known coronary artery disease risk factors.
- Pursuant to her obstetrician’s standing order for non-breastfeeding mothers, she took Parlodel (bromocriptine) 2.5 mg twice daily for 14 days to suppress lactation.
- Five to six days postpartum, while taking Parlodel, she developed chest pain and was diagnosed with an acute myocardial infarction (AMI).
- A cardiologist attributed the AMI to coronary artery spasm and advised avoiding drugs with vasoconstrictive effects.
- Melissa and her husband sued the drug manufacturer, alleging Parlodel caused vasoconstriction/coronary vasospasm leading to AMI and that the drug was negligently marketed for lactation suppression without adequate warnings.
- In a federal diversity action, the manufacturer moved for summary judgment on medical causation, arguing plaintiffs’ expert causation opinions were inadmissible under Federal Rule of Evidence 702 and Daubert.
- The court conducted a multi-day evidentiary hearing focused on the reliability of the proffered causation methodologies and supporting scientific materials.

## Issues

1. Whether plaintiffs’ expert opinions that Parlodel can cause coronary vasospasm and caused Globetti’s AMI were sufficiently reliable under Federal Rule of Evidence 702 and Daubert to be admitted.
2. If the expert opinions were admissible, whether the manufacturer was entitled to summary judgment for lack of proof of medical causation.

## Decision

- The court held plaintiffs’ expert medical-causation opinions were admissible under Rule 702 and Daubert.
- The court denied the manufacturer’s motion for summary judgment on medical causation.
- The court ruled that disputes about the strength of the scientific support largely concerned the weight of the evidence for the factfinder rather than admissibility.

## Legal Principles

- Under Rule 702 and Daubert (as applied to technical and medical testimony), the court’s gatekeeping task is to assess methodological reliability, not to decide which side’s scientific conclusion is correct.
- Medical-causation testimony may be reliable even without definitive epidemiologic studies when supported by converging evidence such as pharmacology, biological mechanism, animal or experimental data, adverse-event information, and clinical reasoning.
- Differential diagnosis is a recognized method for specific causation when experts systematically consider and rule out alternative causes and connect the remaining explanation to the clinical course and timing.
- Challenges that target gaps in the data, the absence of a single “best” study type, or competing expert interpretations typically affect weight and cross-examination, not admissibility, when the proffered methodology is scientifically grounded.
- When admissible expert testimony creates a genuine dispute on causation, summary judgment on causation is improper.

## Conclusion

The court admitted plaintiffs’ causation experts after finding their multi-source methodology and differential diagnosis reliable under Rule 702 and Daubert, and it denied summary judgment because competing expert views created triable issues on whether Parlodel caused the postpartum AMI.


Globetti v. Sandoz Pharms. Corp., 111 F. Supp. 2d 1174 (N.D. Ala. 2000)